Memorandum Findings of Fact and Opinion
Respondent has determined herein a deficiency in estate tax in the amount of $11,534.41. That part of the deficiency is here in issue which results from respondent including in the gross estate of Helen Schwartz, deceased, the sum of $50,204.17, representing the payment made in that amount to decedent's husband pursuant to the terms of an annuity contract in which decedent was named as annuitant and decedent's husband was...
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